Tonix Pharmaceuticals Holding Corp.
509 Madison Avenue, Suite 1608
New York, New York 10022
April 15, 2020
VIA EDGAR
United States Securities and Exchange Commission
Division of Corporation Finance
100 F Street, N.E.
Washington, D.C. 20549
| Re: | Tonix Pharmaceuticals Holding Corp. |
| | Registration Statement on Form S-1 (File No. 333-237610) |
| | Filed on April 8, 2020 |
Ladies and Gentlemen:
In accordance with Rule 461 under the Securities Act of 1933, as amended, Tonix Pharmaceuticals Holding Corp. hereby requests that the above-referenced Registration Statement (the “Registration Statement”) be declared effective by the Securities and Exchange Commission at 4:00 p.m., Eastern Time, on April 17, 2020, or as soon as practicable thereafter.
Please call Irina Ishak of Lowenstein Sandler LLP at (973) 422-6406 to confirm the effectiveness of the Registration Statement or with any questions.
[Signature page follows.]
U.S. Securities and Exchange Commission
April 15, 2020
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| Very truly yours, |
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| TONIX PHARMACEUTICALS HOLDINGS CORP. |
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| By: | /s/ Bradley Saenger | |
| Name: | Bradley Saenger |
| Title: | Chief Financial Officer |